G.R. No. 172677, September 12, 2008
Isagani Yambot and Letty Jimenez-Magsanoc, Petitioners, versus Raymundo A. Armovit and Hon. Francisco R. Ranches, in his capacity as the Presiding Judge of Branch 21 of the Regional Trial Court of Vigan, Ilocos Sur, Respondents.

FACTS

Private respondent Raymundo Armovit filed a libel complaint against petitioners, the publisher and editor-in-chief of the Philippine Daily Inquirer, and two reporters, due to news reports published in 1996. The reports allegedly imputed that Armovit harbored or concealed his client, convicted murderer Rolito Go. The Office of the Provincial Prosecutor found probable cause and filed two criminal informations for libel with the Regional Trial Court (RTC). Subsequently, the Regional State Prosecutor, upon review, reversed this finding, prompting the Provincial Prosecutor to file a motion to withdraw the informations.
The RTC, however, denied the motion to withdraw, finding that probable cause existed for the libel charges. The trial court also denied the petitioners’ motion for reconsideration. The petitioners then filed a certiorari petition with the Court of Appeals, which was denied. They elevated the case to the Supreme Court, arguing the RTC gravely abused its discretion in denying the withdrawal and in finding probable cause.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in denying the prosecution’s motion to withdraw the libel informations and in independently finding probable cause against the petitioners.

RULING

The Supreme Court denied the petition, finding no grave abuse of discretion by the trial court. The Court emphasized the doctrine established in Crespo v. Mogul, which holds that once a complaint or information is filed in court, any disposition of the case rests within the sound discretion of that court. The court is the sole judge of what to do with the case before it. While the resolution of the prosecutor is persuasive, it is not binding on the court. The trial court may therefore grant or deny a motion to dismiss or withdraw an information based on its own independent assessment of the records of the preliminary investigation, in the faithful exercise of judicial discretion.
Applying this, the Supreme Court found that the RTC properly exercised its prerogative. The trial court’s order demonstrated it made its own assessment of the preliminary investigation records, noting the defamatory imputations and the lack of evidence from the accused to prove their truth. The Court held that the RTC complied with its duty to determine the motion’s merits, and its ruling was not tainted with grave abuse of discretion. The Court further ruled that it could not review the evidence on probable cause in this certiorari proceeding absent a showing of such abuse. The petitioners’ other arguments regarding the nature of the news reports were deemed matters of defense best ventilated during trial.